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Terminate DC plan prior to Cycle 3 restatement deadline?

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Client has not yet restated DC plan for Cycle 3. Client is willing to sign interim amendment for a plan terminating in 2022. What are the issues if he terminates the plan prior to 7/31/2022, the Cycle 3 restatement deadline, without actually restating the plan for Cycle 3?

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You don't NEED to restate, but you do need to make sure the plan is fully up to date with law and regulations (even if interim amendments are not yet due) and the best way to ensure that is to restate and include the plan provider's amendment for terminating plans. 

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services


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